M/S. UNITED ENGINEERS, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, RAJKOT, RAJKOT

In the result, the above appeals of the assessee are partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

reassess the income of "other person" in accordance with the provisions of section 153A of the Act, if the AO of the "other person" is satisfied that books of account/ documents/ assets seized/ requisitioned have a bearing on the determination of total income of such "other person". Thus, after initiation of proceedings u/s 153C, the machinery provisions of section 153A

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

reassessment as the case may be. In case AO has not done so, the order framed under section 143(3) read with section 147 of the Act becomes invalid. ITA Nos.31,32 & 38to40/Rjt/2020 A.Y. 2010-11 to 2012-13 7 13. Now coming to second question whether the notice under section 143(2) issued beyond the statutory time limit provided

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita Nos. 31 & 32/Rjt/2020 िनधा"रणवष"/Asstt. Years:2011-12, 2012-13 िनधा"रणवष" िनधा"रणवष" िनधा"रणवष"

reassessment as the case may be. In case AO has not done so, the order framed under section 143(3) read with section 147 of the Act becomes invalid. ITA Nos.31,32 & 38to40/Rjt/2020 A.Y. 2010-11 to 2012-13 7 13. Now coming to second question whether the notice under section 143(2) issued beyond the statutory time limit provided

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

reassess the income of "other person" in accordance with the provisions of section 153A of the Act, if the AO of the "other person" is satisfied that books of account/ documents/ assets seized/ requisitioned have a bearing on the determination of total income of such "other person". Thus, after initiation of proceedings u/s 153C, the machinery provisions of section 153A

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

reassess the income of "other person" in accordance with the provisions of section 153A of the Act, if the AO of the "other person" is satisfied that books of account/ documents/ assets seized/ requisitioned have a bearing on the determination of total income of such "other person". Thus, after initiation of proceedings u/s 153C, the machinery provisions of section 153A

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

reassess the income of "other person" in accordance with the provisions of section 153A of the Act, if the AO of the "other person" is satisfied that books of account/ documents/ assets seized/ requisitioned have a bearing on the determination of total income of such "other person". Thus, after initiation of proceedings u/s 153C, the machinery provisions of section 153A

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

reassess the income of "other person" in accordance with the provisions of section 153A of the Act, if the AO of the "other person" is satisfied that books of account/ documents/ assets seized/ requisitioned have a bearing on the determination of total income of such "other person". Thus, after initiation of proceedings u/s 153C, the machinery provisions of section 153A

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

reassess the income of "other person" in accordance with the provisions of section 153A of the Act, if the AO of the "other person" is satisfied that books of account/ documents/ assets seized/ requisitioned have a bearing on the determination of total income of such "other person". Thus, after initiation of proceedings u/s 153C, the machinery provisions of section 153A

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

In the result the appeal filed by the assessee is allowed partly for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

10 143(3) were going on/in process, the notice under section 148 of the Act dated 17-08-2015 was issued by the AO for the same assessment year. It is the settled provisions of law there cannot be 2 assessments for the same assessment years simultaneously as held by the Hon’ble Gujarat High Court in the case

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

10 (ii)On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition u/s.68 of Rs.85,00,000/- of unsecured loans received from M/s. Mansarovar Financial Services Ltd and M/s. Suramya Tradelinks Pvt Ltd; (iii)The Ld. CIT(A), before sustaining the addition u/s 68 of unsecured loans received of Rs.85

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 143(3) of the Act, should be treated invalid, and therefore, the reassessment order framed by the assessing officer, may be be quashed and for that, learned Counsel for the assessee relied on the judgement of Hon’ble High Court of Allahabad in the case of Vikas Gupta (2022) 142 taxmann.com 253 (Allahabad HC). The learned Counsel also relied